Table of Contents
- Responsible Parties - Who are we?
- Data Protection Officer
- What Rights do you have?
- Deletion of Data and Storage period of Data
- Data Collection in DRAG
- How is your Personal Data Protected?
- App Permissions
- Contact us for support
- Payment handling
- Personal Data of Children
- Change of Data Privacy Statement
1. Responsible Parties - Who are we?
GearEight Games UG (haftungsbeschränkt)
2. Data Protection Officer
You can reach our data protection officer through the contact channels listed above.
3. What Rights do you have
You can contact us any time if you have questions regarding your data protection rights or want to assert any of
your following rights:
- Right of revocation according to Article 7 Paragraph 3 GDPR (for example, you can turn to us in
case you would like to revoke a formerly given agreement for a newsletter)
- Right of Information according to Article 15 GDPR (for example, you can turn to us if you want to
know which data of yours we have saved)
- Rectification according to Article 16 GDPR (for example, you can turn to us in case your e-mail
has changed or you would like us to update an older e-mail)
- Deletion according to Article 17 GDPR (for example, you can turn to us if you would like us to
delete certain data about you which we have saved)
- Restriction of processing according to Article 18 GDPR (for example, you can turn to us if you
want us to use your e-mail only for sending you absolutely necessary e-mails)
- Data Portability according to Article 20 GDPR (for example, you can turn to us in order to receive
your saved data in a compacted format, for example, when you want to provide another website with your
- Objection according to Artice 21 GDPR (for example you can turn to us when you don't agree with
promotional or analysis methods used in our services)
- Right of appeal at the controlling authority in charge according to Article 77, Paragraph 1 GDPR
(for example, you can also direct your complaints straight to the Data Protection Authorities)
4. Deletion of Data and Storage period of Data
Unless stated otherwise, we delete your data as soon as we do not need it any more. Blocking or deletion of your
data may also occur if a legally mandated storage limitation has been reached, unless there is a further need to
save the data for a contract closing or a contractual performance. Certain data might have to be saved longer for
legal reasons. Of course, you can contact us anytime to obtain information about the saved data.
5. Data Collection in DRAG
DRAG does not collect any personal data about you or your smartphone. However, we use Unity Analytics to analyze
the progress of our players and gather information about how long it takes for them to solve puzzles. This
information is not personalized and we cannot identify you by the data since it is completely anonymous.
6. How is your Personal Data Protected?
The collected data is stored on the servers of Unity Technologies, the company that runs all services used by the
7. App Permissions
When you download DRAG or make in-app purchases via a distribution platform (e.g. the Apple AppStore or the
Google PlayStore), this platform will receive certain information about your account, such as your name, device
type, e-mail address and payment information. We have no influence over this data collection and are not
responsible for it.
Because we want to provide you with in-App purchases and advertisements, we require an internet connection.
We also disable the sleep mode of your smartphone while you are solving puzzles (so not in the menus, just when
you have a puzzle on your screen), because it could distract you.
On Android we may also access your external storage to store data relevant for running the app, like your
settings or your progress in the game. We cannot access any other data on your phone or the external storage.
8. Contact us for support
If you have any problems with the app, you can reach us at email@example.com.
We may ask about the following:
- Distribution platform
- Operating system (iOS, Android)
- Hardware (e.g. your smartphone)
- Actions done within the game or on your phone, depending on context
For security reasons, all support requests are handled over an encryptet connection. We will delete all data
gathered about you once the support interaction is terminated.
We do not use any of this information for any other purposes besides contacting and supporting you.
The legal basis is your approval (Art. 6, para. 1, lit. a GDPR) and the fulfillment of a contract (Art. 6,
para. 1 lit. b GDPR).
9. Payment handling
Purchases of in-app products are handled by the distribution platform from which you downloaded the game. When
you initialize the payment process in order to purchase premium currency, you will need to enter additional
data. Which those are depends on the payment method you selected. Distribution platforms offer a variety of
services for payment processing which you can choose from.
Often, distribution platforms work together with external payment providers, such as PayPal, credit card
etc. These external payment providers are obligated by law to handle your data securely, and they are only
to use your data as far as it is necessary for the fulfilment of their task.
You are free to choose which payment providers you use; you can read up on the data privacy statements and notes
the matter on the sites of the distribution platforms and payment prociders.
Once a transaction is completed successfully, the distribution platforms send feedback to us, confirming the
success of the transaction.
This application provides users the option of being served video advertisements from a Unity Technologies in
exchange for in-game rewards, but also shows skippable advertising during regular play sessions. We do not
any collected information with these third-party advertisers but they may collect and store their own
11. Personal Data of Children
We do not collect any identifyable personal data and so cannot determine which data was created by children. We
neither intentionally collect personal, individually identifiable information about children under the age of 16,
nor do we offer content for children under 16.
12. Change of Data Privacy Statement
GearEight Games reserves the right to cange this data privacy statement at any time, however, we will always adhere
to the currently applicable data security laws. We will inform you about any changes when you visit our website.
Last updated: January 2019